Data Protection and Privacy Policy

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ADICCTI CREATIVE DESIGN

INTRODUCTION

ADICCTI CREATIVE DESIGN has its head office at Rua Gil Eanes, 5ª, R/C, Tunes, 8365-235, Silves, and can be contacted at geral@adiccti.com. A brand of Original e Assertivo, Lda., with tax number 517221497 and license number 115739-PAR.

The privacy policy described below provides you with an overview of how ADICCTI CREATIVE DESIGN processes your personal data and your rights in this regard, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council – General Data Protection Regulation (“GDPR”) and other applicable privacy and data protection legislation. The specific personal data that will be processed and the way in which it will be used depends to a large extent on the services requested by you and agreed with you.

This privacy policy applies to the personal data of Users of our Sites, Clients, Suppliers and Candidates, whenever they are natural persons.

Each time you use the Site you are subject to the application of the Privacy and Cookies Policy in force at any given time, so we suggest that you read these Policies carefully to check that you agree with their terms.

From time to time, we may change this Privacy Policy. If you wish to keep up to date, please visit this page, as all changes will be published here.

For the purposes of applicable data protection legislation, the company responsible for processing your personal data is ADICCTI CREATIVE DESIGN.

GLOSSARY

Deletion – we will permanently delete your personal data as soon as the retention period ends or when we receive a valid request from you to do so and provided that there are no legitimate interests justifying the retention of your personal data.

Candidates – includes candidates for all roles advertised or promoted by ADICCTI CREATIVE DESIGN, including permanent, part-time and temporary roles and self-employed roles at ADICCTI CREATIVE DESIGN; as well as persons who have submitted a spontaneous CV to ADICCTI CREATIVE DESIGN unrelated to a specific job offer. Individual contractors, self-employed persons and employees of suppliers or other third parties who apply for positions at ADICCTI CREATIVE DESIGN will be treated as applicants for the purposes of this Privacy Policy.

Personal data – any information relating to a natural person which can be directly identified or which makes that person identifiable, directly or indirectly, in particular by reference to an identifier.

Clients – clients and others to whom ADICCTI CREATIVE DESIGN provides services or supplies goods in the course of its business.

Suppliers – refers to partners, consultants, traders (including sole traders) and independent workers or any other entity that supplies goods or provides services to ADICCTI CREATIVE DESIGN.

Staff – includes dependent workers as well as trainees directly involved in ADICCTI CREATIVE DESIGN’s activity.

General Data Protection Regulation (GDPR) – a European Union legal instrument that aims to harmonize European legislation on data protection.

TYPE OF PERSONAL INFORMATION WE COLLECT

ADICCTI CREATIVE DESIGN collects different types of personal data for different purposes, as explained below. We would like to point out that we do not intentionally collect personal information from minors under the age of 18. If we detect that we have unintentionally collected personal information from minors under the age of 18, we will take the necessary steps to delete the information as soon as possible, unless we are obliged by applicable law to retain it.

      • CLIENT DATA: We only collect the data necessary for the preparation, fulfillment and execution of any quotation or service requested by the Client from ADICCTI CREATIVE DESIGN, as well as to respond to any subsequent complaints regarding the same. Normally, we only need to have your contact details (such as name, telephone number, e-mail address, address and zip code) to enable us to ensure that our relationship runs smoothly.

      • SUPPLIER DATA: We only collect the data necessary for the preparation, fulfillment and execution of any contract entered into between the Supplier and ADICCTI CREATIVE DESIGN, as well as to respond to and manage any claims related thereto. We will collect the data of contact persons, including those of your company, such as names, telephone numbers and e-mail addresses. We will also collect bank details.

      • WEBSITE USERS: We only collect the data necessary to guarantee a good experience when using the Website and to allow you to take advantage of all the potential and features it offers, as well as to help us manage the services we provide. This includes information such as how you use our site, how often you access it, your browser type, your IP address, the location from which you visit our site, the language you choose to view it and the times when our site is most popular, as well as other information better described in our cookie policy below.

      • APPLICANT DATA: Depending on the relevant circumstances and applicable local laws and requirements, we may collect all or part of the information listed below: such as name, and contact details (telephone and e-mail), immigration status (in case you need a work permit), a photograph of yourself; employment status and activity, such as education data; employment history; current remuneration, pension and benefit arrangements, if the same is required for the position for which you wish to apply; additional information that you choose to share with us, namely in your cover letter, curriculum vitae or at interviews; additional information that our Clients may share about you or that we discover from other third party sources (aka references);

    Please note that the above list of categories of personal data that we may collect is not exhaustive.

    OBLIGATION TO PROVIDE DATA

    Within the scope of our commercial or employment relationship, you will have to provide the personal data necessary to establish and create that relationship and to fulfill the obligations and pre-contractual and contractual steps derived from it, as well as those that we are legally obliged to collect. Without this data, we will generally have to refuse to enter into or perform the contract or we will not be able to maintain the contract and will have to terminate it.

    If you do not provide us with the necessary information and documentation, we will not be able to establish or continue the commercial or employment relationship that you want, or follow up on your requests.

    HOW WE COLLECT PERSONAL DATA

    We may collect personal data in various ways

        • Personal data that we receive directly from you if you contact us proactively, usually by telephone or e-mail; and/or if we contact you by telephone or e-mail or through business development activities more generally.

        • Enter your details on the ADICCTI CREATIVE DESIGN website using the form as part of the registration process;

        • Send your curriculum vitae by e-mail, via social networks or leave a paper copy;

        • Participate in a contest through a social media channel, such as Facebook, Instagram, or another;

        • Sign up for our newsletter;

        • Personal data we receive from other sources, usually through commercial due diligence or other market information. We also receive personal data from other sources, for example if you “like” our Facebook page or “follow” us on X and/or Instagram and/or Pinterest we will receive personal information from those sites.

        • We collect your data automatically through cookies, in accordance with your browser’s cookie settings.

      LEGAL FOUNDATION

          1. For the provision of products and services: ADICCTI CREATIVE DESIGN may use your personal data when this is necessary to perform the contract between you and ADICCTI CREATIVE DESIGN, as well as to identify you. We may also use your Personal Data to prevent and investigate possible misuse.

          1. Marketing activities: we may, from time to time, send you information that we think may be of interest to you. In particular, we may use your data for the purposes listed below, where appropriate: to allow us to develop commercial or marketing actions, namely to promote actions to publicize new features or new products and services; to send you data on reports, promotions, offers and the establishment of contacts; to provide you with information on certain discounts and offers to which you are entitled due to your relationship with ADICCTI CREATIVE DESIGN to allow us to send you newsletters, which may contain information on promotional campaigns, discounts, promotions and offers, invitations, reminders regarding your bookings, actions to publicize new features, new products or services and to send you information on participation in contests and sweepstakes, in accordance with the thematic preferences you have indicated to us, by email; to provide you with information on personalized and exclusive offers of products and services identified on the basis of your personal preferences and behaviors, as well as from the use of products, services and browsing on the websites.

          1. Other purposes: to store (and update where necessary) your information in our database, so that we can contact you in relation to contracts you wish to enter into/ have entered into with us; to offer you services or to obtain support and services from you; to comply with certain legal obligations; to help us target appropriate marketing campaigns, and ADICCTI CREATIVE DESIGN may adopt automated decisions, including profiling; in rare circumstances, to assist us in asserting, exercising or defending a right and to defend the vital interests of the data subject, we may also use your personal data if we consider it necessary to do so in order to defend our legitimate interests.

          1. Development of products and services: ADICCTI CREATIVE DESIGN may use your personal data for the development of its products and services. However, we will predominantly use aggregated data and statistical information for this purpose. ADICCTI CREATIVE DESIGN keeps track of the pages our customers visit within the website to determine which services/products are most requested. In this case, information is collected regarding the computer or device (including mobile devices) you use to access it, the website through which you accessed ours, the type and language of your browser, operating system, cookies, the country from which you are accessing, referring and exit pages, URL, type of platform, the number of clicks made, domain names, landing pages, pages visited and the order in which you visited them, the time spent on a particular page, the date and time you accessed our website, access errors and other similar information that your browser sends us.

          1. Communication: ADICCTI CREATIVE DESIGN may use your personal data to communicate with you, namely to send you news related to our products or services, or to assist you in aspects related to customer support, namely to respond to and process user requests through customer service channels, as well as monitoring the quality of our service. In this case, your full name, email address and telephone number are collected.

          1. Recruitment activities: in order to fill vacancies, we may carry out recruitment activities internally. We have listed below various ways in which we may use and process your personal data for this purpose:

                • 6.1) Collect your data from you or from other sources, such as LinkeIn or Facebook;

                • 6.2) To store your data (and update it when necessary) in our database so that we can contact you regarding recruitment;

                • 6.3) Evaluate data about you in relation to the vacancies we think are suitable for you;

                • 6.4) To allow you to send your CV, apply online for job vacancies or subscribe to alerts about job vacancies that we think may be of interest to you;

                • 6.5) Comply with our obligations under any contracts entered into between us;

                • 6.6) Comply with our obligations arising from any contracts entered into between ADICCTI CREATIVE DESIGN and third parties relating to your recruitment;

                • 6.7) Streamlining our payroll and invoicing processes;

                • 6.8) Verify the data you have provided, using third party resources (such as psychometric assessments or skills tests) or to request information (such as references, insofar as this is appropriate under applicable law and you have provided us with the details of the reference contacts and obtained their prior consent for the transmission of your personal data, as well as authorizing us to contact them); and

                • 6.9) Comply with our legal obligations, including in particular with regard to the detection of crime or the collection of taxes or duties.

          We use and process your personal data for the management and performance of contracts or other steps requested by the data subject (Art. 6(1)(b) GDPR); within the scope of a legitimate interest (Art. 6(1)(f) GDPR); on the basis of your consent (Art. 6(1)(a) GDPR) and on the basis of a legal imperative or for the benefit of the public interest (Art. 6(1)(c) and (e) GDPR).

          ENTITIES WITH WHICH WE SHARE YOUR PERSONAL DATA

          Where appropriate and in accordance with local laws and requirements, we may share your personal data in various ways and for various reasons with the following categories of people:

              • In the course of an investigation, complaint or procedure, to the Tax Authorities, Audit Authorities, the Administration, Public Bodies, the Court, the Aliens and Borders Service (“SEF”) and the Security Forces, which are responsible for the matter;

              • Third party service providers who perform functions on our behalf (including external consultants, business partners and professional advisors such as lawyers, auditors and accountants, recruitment companies, technical support functions and IT consultants who carry out testing and development work on our company’s technology systems);

              • Third-party providers of outsourced IT and document storage services, where we have an appropriate processing contract (or similar protections);

              • In the event of the acquisition or disposal of businesses or assets, we may share your personal data with the potential acquirers of those businesses or assets;

              • In the case of payments, credit institutions and other payment service providers, as well as technological service providers related to payment services to whom the data is transmitted to carry out the transaction, and who may be obliged by the legislation of the State in which they operate, or by agreements concluded by it, to provide information on transactions to the authorities or official bodies of other countries, located both inside and outside the European Union, in the context of the fight against terrorist financing, serious forms of organized crime and the prevention of money laundering.

            SAFEGUARDING YOUR PERSONAL DATA

            We are committed to taking all reasonable and appropriate steps to protect the personal information we hold from misuse, accidental or unlawful alteration, loss and unauthorized disclosure or access. To this end, ADICCTI CREATIVE DESIGN uses security systems, rules and other procedures to guarantee the protection of your personal data, as well as to prevent unauthorized access to data, improper use, disclosure, loss or destruction.

            If you suspect misuse, loss or unauthorized access to your personal information, please notify us immediately.

            PERSONAL DATA RETENTION

            We only keep your personal data for as long as necessary to achieve the purpose for which we collected it, to respond to your needs, to the requests you address to us, or to comply with our contractual and legal obligations, using the criteria referred to:

                • a) When you purchase products and services, we will keep your personal data for the duration of our commercial relationship, including any complaints that may arise, as well as for the period of ten (10) years after the termination of such relationship, without prejudice to compliance with the controller’s legal obligations;

                • b) When you contact us to ask questions, request information and clarifications, we will keep your personal data for the period necessary to resolve your question/provide the information and/or clarifications requested;

                • c) When you create a customer account, i.e. when you register on our website, we will keep your data until you ask us to delete it or after a period of inactivity of five years;

                • d) In relation to data collected in the recruitment process, for a maximum period of five years after the end of the recruitment process;

                • e) In relation to the use of cookies, we keep them for as long as necessary to achieve the purposes inherent to them, as detailed in the Cookie Policy;

                • f) The time provided for in the applicable legislation; or

                • g) Until the specific purpose applicable to certain data ceases to exist.

                • h) If there is a pending judicial or administrative process, the data will be kept for the duration of the process and for up to six months after the final decision is issued.

              Once the aforementioned storage periods have expired, personal data will be deleted and/or erased in an absolutely secure manner.

              HOW TO ACCESS, CHANGE OR REMOVE THE PERSONAL DATA YOU HAVE PROVIDED TO US

                  • Right to object: this right allows you to object to our processing of your personal data on grounds relating to your particular situation where your personal data is processed for one of the following reasons: (i) our legitimate interests; (ii) to enable us to perform a task in the public interest or exercise official authority; (iii) to send you direct marketing materials, including profiling; and (iv) scientific, historical, research or statistical purposes.

                If you exercise your right to object, we will stop processing the data to which you have objected, unless: we can demonstrate that we have compelling legitimate grounds for the processing which override your interests or we are processing your data for the establishment, exercise or defence of legal claims.

                    • Right to withdraw consent: You may withdraw your consent to the processing of your personal data at any time and we will stop carrying out the specific activity to which you previously consented, unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose, in which case we will inform you of this condition.

                    • Data Subject Access Requests: You may ask us, at any time, to confirm the information we have about you, as well as request additional information about the purposes of the processing, the period for which we retain your data, the existence of automated decisions, the recipients to whom the data is disclosed, among other information provided for in article 15 of the GDPR. We may ask you to verify your identity and provide further information about your order. If we grant you access to information we hold about you, we will not charge you for that access unless your request is “manifestly unfounded or excessive.” If you ask us for additional copies of this information, we may charge a reasonable administrative fee where legally permitted. Where we are legally permitted to do so, we may refuse your order. If we refuse your request, you will always be informed of the reasons for doing so.

                    • Right to be forgotten/erased: In certain circumstances, you have the right to ask us to delete your personal data. Normally, the exercise of this right must meet one of the following criteria: the data is no longer necessary for the purpose for which we originally collected and/or processed it; where you have withdrawn your consent for us to process your data and there is no other valid reason for us to continue to process it; if you object to the processing and there are no overriding legitimate interests justifying it: the data has been unlawfully processed (i.e. in a way that does not comply with the GDPR); or it is necessary for the data to be erased in order for us to comply with our legal obligations as a controller.

                  This right, however, does not apply, and therefore, ADICCTI CREATIVE DESIGN may continue to process your data in a legitimate manner, when this proves necessary:

                      • to exercise the right to freedom of expression and information;

                      • to comply with legal obligations or to perform a task in the public interest or in the exercise of official authority;

                      • for public health reasons in the public interest;

                      • for archival, research or statistical purposes;

                      • for the exercise or defense of a right.

                    Upon compliance with a valid data erasure request, we will take all practical reasonable steps to erase the data.

                    Right to restriction of processing: In certain circumstances, you have the right to restrict our processing of your personal data. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until: (i) one of the circumstances listed below is resolved; (ii) we have obtained your consent; or (iii) further processing is necessary for the establishment, exercise or defence of legal claims, the protection of the rights of another person or for reasons of important public interest of the EU or of a Member State.

                    The circumstances in which you have the right to request the restriction of the processing of your personal data are:

                        • in the event that you contest the accuracy of the personal data we process about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;

                        • in the event that you object to the processing of your personal data for our legitimate interests. In this situation, you can ask for data to be restricted whilst we verify our grounds for processing your personal data;

                        • if our processing of your data is unlawful, but you prefer to restrict our processing of it instead of deleting it; and

                        • if we no longer need to process your personal data, but we need the data to declare, exercise or defend a right.

                      If we have shared your personal data with third parties, they will be notified about the restricted processing, unless this proves impossible or involves a disproportionate effort. We will, of course, notify you before lifting any restriction on the processing of your personal data.

                          • Right to rectification: You have the right to ask us to rectify any inaccurate or incomplete personal data we hold about you. If we have shared such personal data with third parties, they will be notified of the rectification, unless this proves impossible or involves a disproportionate effort. Where appropriate, we will also disclose to you which third parties we have disclosed inaccurate or incomplete personal data to. In cases where we consider it reasonable not to comply with your request, we will explain the reasons for our decision. It is important that the personal information we hold about you is accurate and current. Please let us know if there are any changes to your personal information during the period we hold your data.

                          • Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority, which in Portugal is the National Data Protection Commission. You can contact her in the following ways: Telephone (+351) 213928400 / Privacy Line: +351 21 393 00 39 E-mail: geral@cnpd.pt / Address: Rua de São Bento, nº 148-3º, 1200-821 Lisbon / Fax: +351 21 397 68 32

                        If you wish to exercise any of these rights or withdraw your consent to the processing of your personal data (if consent is our legal basis for processing your personal data), please contact us. Please note that we may keep a record of your communications to help us resolve any concerns you raise.

                        CONTACT

                        If you wish to exercise any of the above rights, suspect misuse, loss or unauthorized access or have any comments or suggestions regarding this Privacy Policy, you can contact us at the following address: geral@adiccti.com

                        WARRANTIES

                        The user guarantees that the personal data communicated to ADICCTI CREATIVE DESIGN is correct and accurate and undertakes to notify any changes or modifications thereto and assumes sole responsibility for losses and damages caused by erroneous, inaccurate or incomplete communication of the data. The user is expressly warned that by disclosing personal data on ADICCTI CREATIVE DESIGN’s public media, such as Facebook, LinkedIn and Instagram, this information may be seen and used by third parties. ADICCTI CREATIVE DESIGN does not read any personal communication published on its clients’ own websites.

                        COOKIE POLICY

                        What is a cookie?

                        A “cookie” is a file of information that is stored on your computer’s hard drive and which records your browsing on a website so that, when you visit that site again, you can be presented with personalized options based on the information stored about your last visit. We may also use cookies on our website to analyze traffic and for advertising and marketing purposes, which do not harm your system. If you want to check or change the type of cookies you accept, you can do so in your browser settings.

                        Cookies collected and used:

                        Website language, user age, browser pixel ratio, session code.

                        Related to google

                        Cookies used for analytics.

                        How do we use cookies?

                        We use cookies to do two things to track your use of our website. This allows us to understand how you use the website and track any patterns that emerge across individuals or larger groups, which will help us to develop and improve our website and services in response to what our visitors want and need; and

                        Consent

                        Under Law No. 41/2004 of 18 August, the storage of information and the possibility of accessing information stored on a user’s terminal equipment (namely through cookies) are only carried out by ADICCTI CREATIVE DESIGN if the user has given their prior and express consent to the installation of cookies on their equipment, therefore we ask that you accept this Privacy and Cookies Policy before using the websites.

                        How to avoid the use of Cookies on websites

                        The Customer has the right to withdraw consent to the use of cookies by ADICCTI CREATIVE DESIGN at any time by deleting the cookies stored on their computer through the configuration options of their Internet browser.

                        Finally, if you wish to have greater control over the installation of cookies, you can install programs or add-ons to your browser, known as “do not track” tools, which will allow you to choose which cookies you wish to allow.

                        If you block or do not authorize the use of cookies, no cookies will be stored on your device, but the proper functioning of our websites is not guaranteed, and therefore the customer will not be able to obtain the maximum benefit from the content made available on the websites, and each time you access the website again, you will always be asked to authorize the use of cookies.

                        DECLARE, EXERCISE OR DEFEND RIGHTS

                        It may sometimes be necessary for us to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data in relation to the exercise or defense of rights. Article 9(2)(f) of the GDPR allows this processing when it is “necessary for the establishment, exercise or defense of legal claims or where the courts are acting in their judicial capacity”. This may arise, for example, where we need to obtain legal advice in relation to legal proceedings or where we are required by law to retain or disclose certain information as part of a legal process.

                        CHANGES TO THE DOCUMENT

                        ADICCTI CREATIVE DESIGN may occasionally change this statement and its Privacy Policy to reflect the company’s image and customer feedback. We encourage you to periodically review our Privacy Policy to stay up to date on how ADICCTI CREATIVE DESIGN protects your information, but we will always inform you if there are any material changes to our Privacy Policy.